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    OSHA violations that you’re making – and don’t even realize

    While dental practices do their best to stay in OSHA’s good graces, these are some common mistakes that offices can make.

    For many employers, the mere mention of the name “OSHA” is met with Bogeyman-like fear and trepidation. However, it’s important to remember that OSHA exists to protect employees. And while practices do their best to stay in OSHA’s good graces, there are some common mistakes that practices may not even realize that they’re making.

    You aren’t training on bloodborne pathogens

    Often, practices make the mistake of not conducting bloodborne pathogen training.

    Related reading: 6 questions about infection control that you might be afraid to ask

    “One of the things I find is that dentists have not provided the bloodborne pathogen training that’s required every year,” says Leslie Canham, CDA, RDA, a consultant and speaker. “Every 12 months they should have a staff meeting and conduct training. But they don’t do it, and this an OSHA violation.”

    “The Code of Federal Regulations (CFR) governing general industry is filled with standards that are relevant to dentistry,” says Karen Daw of Karen Daw Consulting and former clinic health and safety director for The Ohio State University College of Dentistry. “What this means is that OSHA expects the dental employer to know and follow what is outlined here. The most obvious one is the OSHA Bloodborne Pathogens (BBP) standard. Within this is mandatory annual training on the elements of the BBP standard. Common OSHA violations I see have to do with this requirement."

    That training must also be specific to the practice — not some canned, generic instruction.

    “Having an employer understand that even if they send someone off to an OSHA course, they still need to be reviewing their site-specific policies and procedures covering the scope of the bloodborne pathogen standard,” explains Kathy Eklund, RDH, director of occupational health and safety at The Forsyth Institute. “And that would mean some type of site-specific review of the program and training.”

    So, why is this mistake so common?

    According to Canham, “Dentists are busy and, as employers, may not remember everything they’re supposed to do. Sometimes they need a little assistance. For example, an accountant is going to tell the employer when to make payroll deposits and when to adjust for sick pay and things like that. Dentists don’t generally spend a lot of time paying attention to OSHA regulations because they are running a practice, providing patient care, etc., so OSHA compliance isn’t top of mind for them. They believe they are in compliance with OSHA regulations, ‘Yes I have a safe office,’ ‘Yes, we have a First Aid kit,’ and they think that that’s the end of it, but bloodborne pathogen training and reviewing the exposure control plan is mandatory every 12 months.”

    More from the author: 6 ways bulk fills are changing restorative dentistry

    OSHA violationsCanham adds that even though the bloodborne pathogen training must occur every year, OSHA rarely makes broad, sweeping policy changes that affect the entire industry.

    “OSHA doesn’t make big changes very often,” Canham says. “There’s only been a few changes that concern dentistry. In 2013, the Hazard Communication Standard was globally harmonized. So, OSHA adopted the new pictograms, label requirements and ‘material safety data sheets’ started to be called ‘safety data sheets.’ And before that, there was the Needlestick Safety and Prevention Act in 2000. It isn’t like tax law changes where they’re coming at you all the time, or HIPAA regulations. It’s pretty easy to know the basic requirements.”

    The best way to stay up to date with regulatory changes, Canham says, is to be active in your professional organizations, especially the Organization for Safety, Asepsis and Prevention (OSAP).

    “Every dental practice should have at least one person appointed as the infection control or OSHA coordinator and that person should be a member of OSAP,” she says. “OSAP members get newsletters and information on infection control, OSHA compliance and safety for dental settings. OSAP holds annual conferences and infection control boot camps to help dental professionals navigate the sea of regulations and stay abreast of current issues in dental infection control. In addition, members learn how to find information and resources on OSHA compliance. In 2009, when we had the swine flu pandemic, OSAP issued guidance on what we should be looking for in the dental setting and when patients and dental workers should stay home if they’re sick.”

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    Robert Elsenpeter
    Robert Elsenpeter is a freelance writer and frequent contributor to Dental Products Report and Digital Esthetics. He is also the author ...


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